−Removed: American Express is a globally integrated payments company, providing customers with access to products, insights and experiences that enrich lives and build business success.
−Removed: We are a leader in providing credit and charge cards to consumers, small businesses, mid-sized companies and large corporations around the world.
−Removed: American Express ® cards issued by us, as well as by third-party banks and other institutions on the American Express network, can be used by Card Members to charge purchases at the millions of merchants around the world that accept cards bearing our logo.
−Removed: Our various products and services are offered globally to diverse customer groups through various channels, including mobile and online applications, affiliate marketing, customer referral programs, third-party service providers and business partners, direct mail, telephone, in-house sales teams and direct response advertising.
+Added: American Express is a globally integrated payments company with card-issuing, merchant-acquiring and card network businesses that offer products and services to a broad range of customers, including consumers, small businesses, mid-sized companies and large corporations around the world.
+Added: Our range of products and services includes:
+Added: • Credit card, charge card, banking and other payment and financing products
+Added: • Merchant acquisition and processing, servicing and settlement, fraud prevention, and point-of-sale marketing and information products and services
+Added: • Network services
+Added: • Travel and lifestyle services
+Added: • Expense management products and services
+Added: • Other services, such as the design and operation of customer loyalty programs
+Added: These products and services are offered through various channels, including mobile and online applications, affiliate marketing, customer referral programs, third-party service providers and business partners, in-house sales teams, direct mail, telephone and direct response advertising.
We were founded in 1850 as a joint stock association and were incorporated in 1965 as a New York corporation.
7 unchanged sentences
Our Integrated Payments Platform and Technology
−Removed: Through our general-purpose card-issuing, merchant-acquiring and card network businesses, we are able to connect participants and provide differentiated value across the commerce path.
−Removed: We maintain direct relationships with Card Members (as a card issuer) and merchants (as an acquirer), which provides us with direct access to information at both ends of the card transaction, distinguishing our integrated payments platform from the bankcard networks.
+Added: Through our card-issuing, merchant-acquiring and card network businesses, we are able to connect participants and provide differentiated value across the commerce path.
+Added: We maintain direct relationships with Card Members (as a card issuer) and merchants (as an acquirer), which provides us with access to information at both ends of the card transaction, distinguishing our integrated payments platform from the bankcard networks.
Through contractual relationships, we also obtain information from third-party card issuers, merchant acquirers, aggregators and processors with whom we do business.
−Removed: Our integrated payments platform and the systems and infrastructure that underlie it allow us to analyze information on Card Member spending, build models and use analytical tools to help us underwrite risk, reduce fraud and provide targeted marketing and other information services for merchants and partners and special offers and services to Card Members, all while maintaining our commitment to respect Card Member preferences and protect Card Member and merchant data in compliance with applicable policies and legal requirements.
−Removed: We also leverage technology to allow for faster introduction and greater differentiation of products, as well as to develop and improve our service capabilities to continue to deliver a high-quality customer experience.
+Added: Our integrated payments platform and the systems and infrastructure that underlie it provide us with data and analytics, while maintaining our commitment to respect Card Member preferences and protect Card Member and merchant data in compliance with applicable policies and legal requirements.
+Added: Our models and analytical tools help us reduce fraud and underwrite risk, such as in determinations regarding the extension of credit.
+Added: We also leverage our technology to provide differentiated value to customers, such as special offers and benefits to Card Members and targeted marketing and other information services for merchants and partners, as well as to develop and improve our service capabilities to continue to deliver a high-quality customer experience.
Card Issuing Businesses
−Removed: Our global proprietary card-issuing businesses are conducted through our USCS, CS and ICS reportable operating segments.
−Removed: We offer a broad set of card products, rewards and services to a diverse consumer and commercial customer base, in the United States and internationally.
+Added: We are a leader in providing general purpose credit and charge cards to consumers, small businesses, mid-sized companies and large corporations.
+Added: We offer a broad set of card products, rewards and services to this premium consumer and broad commercial customer base, in the United States and internationally, through our USCS, CS and ICS reportable operating segments.
+Added: We focus on differentiating American Express Membership through premium products, lifestyle services for consumers and business-centric solutions for our commercial customers, and benefits for our Card Members that we co-create and co-fund with our business partners.
+Added: We believe the many benefits that come with American Express Membership build a strong, emotional connection with our brand across generations and geographies.
We acquire and retain high-spending, engaged and creditworthy Card Members by:
• Designing innovative credit, charge and debit card products and payment and lending solutions that appeal to our target customer base and meet their spending and borrowing needs
−Removed: • Using incentives to drive spending on our various card products and increase customer engagement, including our Membership Rewards ® and Amex ® Offers programs, cash-back reward features, interest rates offered on deposits and participation in loyalty programs sponsored by our cobrand and other partners
+Added: • Using incentives to drive spending on our various card products and increase customer engagement, including our Membership Rewards ® and Amex Offers ™ programs, cash-back reward features, statement credits for purchases with partners, interest rates offered on deposits and participation in loyalty programs sponsored by our cobrand and other partners
• Providing digital and mobile services and an array of benefits and experiences across card products, such as lounge access, dining experiences and other travel and lifestyle benefits
• Creating world-class service experiences by delivering exceptional customer care
−Removed: • Developing a wide range of partner relationships, including with other corporations and institutions that sponsor certain of our cards under cobrand arrangements and provide benefits and services to our Card Members
−Removed: Over the last several years, we have focused on broadening the appeal of our products to attract new customers, particularly Millennial and Gen Z customers, as well as expanding our position with small and mid-sized enterprise (SME) customers by providing more ways to help them manage and grow their businesses.
−Removed: We have a number of products that complement our card products, such as our business checking and consumer rewards checking account products, our business-to-business (B2B) payment products and other non-card payment and financing products, our Business Blueprint digital cash flow management hub, our Resy restaurant platform and other new digital capabilities.
−Removed: Additionally, we are focused on driving growth and efficiencies internationally, including a greater focus on local priorities in international jurisdictions.
+Added: • Developing a wide range of partner relationships, including designing, cobranding and distributing certain of our cards and providing benefits and services to our Card Members
+Added: We have a number of products that complement our card products, such as our business checking and consumer rewards checking account products, expense management and business-to-business (B2B) payment products and other non-card payment and financing products.
+Added: Our complementary products also include digital capabilities, such as our Business Blueprint digital cash flow management hub and our Resy ® dining platform, which we are enhancing through our acquisitions in 2024 of Tock, a reservation, table and event management technology provider and Rooam, a technology company that powers systems used by restaurants and entertainment venues.
+Added: We are focused on enhancing the value propositions of our products to increase engagement with existing customers and attract new customers, including Millennial and Gen Z consumers as well as customers internationally.
Jurisdictions that represent a significant portion of our billed business outside of the United States include the United Kingdom (UK), the European Union (EU), Australia, Japan, Canada and Mexico.
−Removed: For the year ended December 31, 2023, worldwide billed business (spending on American Express cards issued by us) was $1,460 billion and at December 31, 2023, we had 80.2 million proprietary cards-in-force worldwide.
+Added: For the year ended December 31, 2024, worldwide billed business (spending on American Express cards issued by us) was $1,551 billion and as of December 31, 2024, we had 83.6 million proprietary cards-in-force worldwide.
Merchant Acquiring Business
9 unchanged sentences
These network partners are licensed to issue local currency American Express-branded cards in their countries and/or serve as the merchant acquirer for local merchants on our network.
−Removed: For the year ended December 31, 2023, worldwide network services processed volume (spending on American Express cards issued by third parties) was $220.5 billion and at December 31, 2023, we had 61.0 million cards-in-force issued by third parties worldwide.
+Added: For the year ended December 31, 2024, worldwide network services processed volume (spending on American Express cards issued by third parties) was $213.9 billion and as of December 31, 2024, we had 62.8 million cards-in-force issued by third parties worldwide.
Diverse Customer Base and Global Footprint
−Removed: Our broad and diverse customer base spans consumers, small businesses, mid-sized companies and large corporations around the world.
The following chart provides a summary of our diverse set of customers and broad geographic footprint based on worldwide network volumes:
2 unchanged sentences
There are many examples of how we work with partners, including:
−Removed: issuing cards under cobrand arrangements with other corporations and institutions (e.g., Delta Air Lines (Delta), Marriott International, Hilton Worldwide Holdings and British Airways);
−Removed: offering innovative ways for our Card Members to earn and use points with our merchants (e.g., Pay with Points at Amazon.com);
+Added: issuing cards under cobrand arrangements with other corporations and institutions (e.g., Delta Air Lines (Delta), Hilton Worldwide Holdings, Marriott International and British Airways);
providing greater value to our Card Members (e.g., Amex Offers and statement credits for purchases with partners);
+Added: offering innovative ways for our Card Members to earn and use points with our merchants (e.g., Pay with Points at Amazon.com);
expanding merchant acceptance with third-party acquirers and processors (e.g., OptBlue partners);
1 unchanged sentence
developing new capabilities and features with our digital partners (e.g., PayPal and i2c);
−Removed: integrating into the supplier payment processes of our business customers (e.g., BILL and Extend);
−Removed: and enhancing our travel benefits and services (e.g., Fine Hotels and Resorts).
−Removed: We also have a significant ownership position in, and extensive commercial arrangements with, Global Business Travel Group, Inc.
+Added: enhancing our travel benefits and services (e.g., Fine Hotels and Resorts ® );
+Added: and providing experiences and entertainment for Card Members (e.g., via Formula 1 and AEG Worldwide).
+Added: We also have an ownership position in, and commercial arrangements with, Global Business Travel Group, Inc.
(GBTG), which provides business travel-related services.
1 unchanged sentence
Our relationships with, and revenues and expenses related to, Delta are significant and represent an important source of value for our Card Members.
−Removed: We issue cards under cobrand arrangements with Delta and the Delta cobrand portfolio represented approximately 10 percent of worldwide network volumes and approximately 21 percent of worldwide Card Member loans as of December 31, 2023.
+Added: We issue cards under cobrand arrangements with Delta and the Delta cobrand portfolio continued to represent approximately 12 percent of worldwide billed business and approximately 21 percent of worldwide Card Member loans as of December 31, 2024.
The Delta cobrand portfolio generates fee revenue and interest income from Card Members and discount revenue from Delta and other merchants for spending on Delta cobrand cards.
4 unchanged sentences
Our “spend-centric” business model focuses on generating revenues primarily by driving spending on our cards and secondarily through finance charges and fees.
−Removed: Spending on our cards, which is higher on average on a per-card basis versus our network competitors, offers superior value to merchants in the form of loyal customers and larger transactions.
+Added: Spending on our cards, which is higher on average on a per-card basis versus our network competitors, offers superior value to merchants in the form of loyal customers and larger transactions, and attracts partners to provide value to our Card Members and merchants.
Because of the revenues generated from having high-spending Card Members and the annual card fees we charge on many of our products, we are able to invest in attractive rewards and other benefits for Card Members, as well as targeted marketing and other programs and investments for merchants.
14 unchanged sentences
Finally, we want to continue to build on our unique global position, seeking ways to use our differentiated business model and global presence as we progress against our other strategic imperatives.
−Removed: We also have an Environmental, Social and Governance (ESG) strategy that focuses on three pillars.
−Removed: The Building Financial Confidence pillar seeks to provide responsible, secure and transparent products and services to help people and businesses build financial resilience.
−Removed: The Advancing Climate Solutions pillar focuses on enhancing our operations and capabilities to meet customer and community needs in the transition to a low-carbon future.
−Removed: Finally, the Promoting Diversity, Equity and Inclusion (DE&I) pillar supports a diverse, equitable and inclusive workforce, marketplace and society.
+Added: We have completed the environmental, social and governance goals under our 2021–2024 strategy, other than our continued work in support of Small Business Saturday and other Shop Small campaigns that will progress in 2025 and beyond.
+Added: We are reviewing our approach on these topics as mandatory reporting requirements evolve globally.
Our Colleagues
1 unchanged sentence
As of December 31, 2024, we employed approximately 75,100 people, whom we refer to as colleagues, with approximately 25,800 colleagues in the United States and approximately 49,300 colleagues outside the United States.
−Removed: In 2023, we continued to invest in our colleagues, building on a wide range of learning and development opportunities and enhancing our competitive benefits in key areas including holistic health and wellness, total compensation and flexibility.
−Removed: We conduct an annual Colleague Experience Survey to better understand our colleagues’ needs and overall experience at American Express, and in 2023, 91 percent of colleagues who participated in the survey said they would recommend American Express as a great place to work.
−Removed: To attract and retain the best talent, we strive to offer a compelling value proposition to our colleagues, which represents the ways in which we support our colleagues in four key areas:
−Removed: (1) our culture;
−Removed: (2) career growth and development;
−Removed: (3) rewards and holistic well-being;
−Removed: and (4) diversity, equity and inclusion.
−Removed: Our culture is built on strong relationships, shared values and purpose and a commitment to back our customers, communities and each other.
−Removed: At the heart of our culture is what we call our Blue Box Values – a set of guiding principles that serve as the foundation for how we operate:
−Removed: We Do What’s Right
−Removed: We Embrace Diversity
−Removed: We Back Our Customers We Stand for Equity and Inclusion
−Removed: We Make It Great We Win as A Team
−Removed: We Respect People We Support Communities
−Removed: Career Growth and Development
+Added: As of December 31, 2024, women represented 52.6 percent of our global workforce;
+Added: Asian, Black/African American and Hispanic/Latino/a people represented 22.4 percent, 14.2 percent and 14.5 percent, respectively, of our U.S.
+Added: workforce based on preliminary data for our 2024 U.S.
+Added: EEO-1 submission;
+Added: and 55 percent of our Executive Committee were women or from diverse races and ethnic backgrounds.
+Added: We believe that maintaining our strong workplace culture, adhering to our Blue Box values and ensuring that our people feel included, valued, recognized and backed helps us attract, retain and develop the right talent for American Express’ success.
+Added: We conduct an annual Colleague Experience Survey and in 2024, 90 percent of colleagues who participated in the survey said they would recommend American Express as a great place to work.
+Added: We strive to offer a compelling colleague value proposition, which represents the many ways in which we support our colleagues to be and deliver their best.
+Added: In 2024, we continued to invest in our colleagues, building on a wide range of learning and development opportunities and enhancing our competitive benefits in key areas including total compensation and holistic health and wellness.
We continuously invest in programs, benefits and resources to foster the personal and professional growth of our colleagues.
2 unchanged sentences
career coaching, mentoring, professional networking, and rotation opportunities, as well as courses on-demand and with classroom-style instruction.
−Removed: Rewards and Holistic Well-Being
We aim to provide our colleagues with competitive compensation and leading benefits and take a holistic approach to well-being, providing resources that address the physical, financial and mental health of our colleagues.
Our financial well-being program, Smart Saving, provides tools and resources to help colleagues build their knowledge and skills for all life stages.
−Removed: We support our colleagues’ physical health and well-being through our corporate wellness program, Healthy Living.
−Removed: We also provide resources and support to increase awareness about mental health among our colleagues through our Healthy Minds Program.
−Removed: Diversity, Equity and Inclusion
−Removed: We continue to work to build an inclusive and diverse workplace that values our colleagues’ voices, rewards teamwork, celebrates different points of view and reflects the diversity of the communities in which we operate.
−Removed: As of December 31, 2023, women represented 53.2 percent of our global workforce and Asian, Black/African American and Hispanic/Latinx people represented 20.6 percent, 15.6 percent and 14.3 percent, respectively, of our U.S.
−Removed: workforce based on preliminary data for our 2023 U.S.
−Removed: EEO-1 submission.
−Removed: As of December 31, 2023, 50 percent of our Executive Committee were women or from diverse races and ethnic backgrounds (based on self-identified characteristics).
−Removed: We also regularly review our compensation practices to ensure colleagues in the same job, level and location are compensated fairly regardless of gender globally, and regardless of race and ethnicity in the United States.
−Removed: These reviews consider several factors known to affect compensation, including role, level, tenure, performance and geography.
−Removed: In the instances where a review has found inconsistencies, we have made adjustments.
−Removed: After making these adjustments, we believe we maintained 100 percent pay equity in 2023 for colleagues across genders globally and across races and ethnicities in the United States.
+Added: We support our colleagues’ physical health and well-being through our corporate wellness program, Healthy Living and we provide resources and support to increase awareness about mental health among our colleagues through our Healthy Minds Program.
+Added: We also have policies and processes in place to help ensure we compensate colleagues fairly and equitably.
+Added: We review our compensation practices regularly and have conducted an annual pay equity review since 2017, assessing pay on a statistical basis and considering key factors known to affect compensation, such as role, level, tenure, performance and geography.
+Added: In 2024, we maintained 100 percent pay equity, meaning no statistical differences in pay, for colleagues across genders globally and across races and ethnicities in the United States.
Information About Our Executive Officers
6 unchanged sentences
Prior thereto, he had been Group President, Global Consumer Services Group since February 2018.
−Removed: CAMPBELL — Vice Chairman
−Removed: Campbell (63) has been Vice Chairman since April 2021.
−Removed: He also served as Chief Financial Officer (CFO) from August 2013 to August 2023.
−Removed: HOWARD GROSFIELD — President, U.S.
+Added: HOWARD GROSFIELD — Group President, U.S.
Consumer Services
−Removed: Grosfield (55) has been President, U.S.
−Removed: Consumer Services since May 2022.
−Removed: Prior thereto, he had been Executive Vice President and General Manager of U.S.
+Added: Grosfield (56) has been Group President, U.S.
+Added: Consumer Services since February 2025.
+Added: Prior thereto, he had been President, U.S.
+Added: Consumer Services since May 2022, Executive Vice President and General Manager of U.S.
Consumer Marketing and Global Premium Services since February 2021 and Executive Vice President and General Manager of U.S.
2 unchanged sentences
Herena (53) has been Chief Colleague Experience Officer since April 2019.
−Removed: Herena joined American Express from BNY Mellon, where she served as the Chief Human Resources Officer and Senior Executive Vice President, Human Resources, Marketing and Communications since 2014.
−Removed: RAYMOND JOABAR — Group President, Global Merchant and Network Services
−Removed: Joabar (58) has been Group President, Global Merchant and Network Services since April 2021.
−Removed: Prior thereto, he had been President, Global Risk and Compliance and Chief Risk Officer since September 2019.
−Removed: He also served as President of International Consumer Services and Global Travel and Lifestyle Services from February 2018 to September 2019.
+Added: RAYMOND JOABAR — Group President, Global Commercial Services
+Added: Joabar (59) has been Group President, Global Commercial Services since February 2025.
+Added: Prior thereto, he had been Group President, Global Merchant and Network Services since April 2021 and President, Global Risk and Compliance and Chief Risk Officer since September 2019.
CHRISTOPHE Y.
Chief Financial Officer
−Removed: Le Caillec (58) has been CFO since August 2023.
+Added: Le Caillec (59) has been Chief Financial Officer (CFO) since August 2023.
Prior thereto, he had been Deputy CFO since December 2021 and Head of Corporate Planning since February 2019.
−Removed: He also served as Business CFO for the Global Consumer Services Group from May 2016 to February 2019.
RAFAEL MARQUEZ —
1 unchanged sentence
Marquez (53) has been President, International Card Services since May 2022.
−Removed: Prior thereto, he had been President, International Consumer Services and Global Loyalty Coalition since September 2019 and Executive Vice President of International Consumer Services Europe, Joint Ventures EMEA and International Member Engagement from November 2015 to September 2019.
−Removed: ANNA MARRS — Group President, Commercial Services and Credit & Fraud Risk
−Removed: Marrs (50) has been Group President, Commercial Services and Credit & Fraud Risk since April 2021.
−Removed: Prior thereto, she had been President, Commercial Services since September 2018.
+Added: Prior thereto, he had been President, International Consumer Services and Global Loyalty Coalition since September 2019.
+Added: ANNA MARRS — Group President, Global Merchant and Network Services
+Added: Marrs (51) has been Group President, Global Merchant and Network Services since February 2025.
+Added: Prior thereto, she had been Group President, Global Commercial Services and Credit & Fraud Risk since April 2021 and President, Global Commercial Services since September 2018.
GLENDA MCNEAL —
2 unchanged sentences
Prior thereto, she had been President, Enterprise Strategic Partnerships since March 2017.
−Removed: DAVID NIGRO — Chief Risk Officer
−Removed: Nigro (62) has been Chief Risk Officer since April 2021.
−Removed: Prior thereto, he had been Executive Vice President and Chief Credit Officer, Global Consumer Services and Credit and Fraud Risk Capability since April 2018.
−Removed: DENISE PICKETT — President, Global Services Group
−Removed: Pickett (58) has been President, Global Services Group since September 2019.
−Removed: Prior thereto, she had been Chief Risk Officer and President, Global Risk, Banking & Compliance since February 2018.
+Added: DENISE PICKETT — President, Enterprise Shared Services
+Added: Pickett (59) has been President, Enterprise Shared Services since February 2025.
+Added: Prior thereto, she had been President, Global Services Group since September 2019.
RAVI RADHAKRISHNAN — Chief Information Officer
2 unchanged sentences
Prior thereto, he had been Chief Information Officer, Wholesale, Wealth & Investment Management and Innovation from May 2019 to May 2020.
−Removed: He also served as Enterprise Chief Information Officer from March 2017 to May 2019.
ELIZABETH RUTLEDGE — Chief Marketing Officer
4 unchanged sentences
Skyler (48) has been Chief Corporate Affairs Officer since October 2019.
−Removed: Skyler joined American Express from WeWork, where she served as Chief Communications Officer from January 2018 to September 2019.
SQUERI — Chairman and Chief Executive Officer
Squeri (65) has been Chairman and Chief Executive Officer since February 2018.
−Removed: ANRÉ WILLIAMS — Group President, Enterprise Services
−Removed: Williams (58) has been Group President, Enterprise Services since April 2021.
−Removed: Prior thereto, he had been Group President, Global Merchant and Network Services since February 2018.
−Removed: Williams also serves as the Chief Executive Officer of American Express National Bank.
−Removed: We compete in the global payments industry with card networks, issuers and acquirers, paper-based transactions (e.g., cash and checks), bank transfer models (e.g., wire transfers and Automated Clearing House, or ACH), as well as evolving and growing alternative mechanisms, systems and products that leverage new technologies, business models and customer relationships to create payment, financing or banking solutions.
−Removed: The payments industry continues to undergo dynamic changes in response to evolving technologies, consumer habits and merchant needs, such as an increased shift to digital payments.
+Added: DOUGLAS TABISH —
+Added: Chief Risk Officer
+Added: Tabish (55) has been Chief Risk Officer since April 2024.
+Added: Prior thereto, he had been Executive Vice President and General Manager of Global Card & Risk Operations since January 2020.
+Added: We compete in the global payments industry with networks, issuers, acquirers and other payment service providers and methods of payment, including paper-based transactions (e.g., cash and checks) and electronic transfers (e.g., wire transfers and Automated Clearing House (ACH)), as well as evolving and growing alternative mechanisms, systems and products that leverage new technologies, business models and customer relationships to create payment, financing or banking solutions.
+Added: The payments industry continues to undergo dynamic changes in response to evolving technologies, consumer habits and merchant needs.
As a card issuer, we compete with financial institutions that issue general-purpose credit and debit cards, as well as businesses that issue private label cards, operate mobile wallets, provide payment services or extend credit.
1 unchanged sentence
We also face competition for partners and other differentiated offerings, such as lounge space in U.S.
−Removed: and global hub airports, restaurant reservation capabilities and other experiential offerings to customers.
+Added: and global hub airports, dining and event reservation and operational capabilities and other experiential offerings to customers.
Our banking products also face strong competition, such as with respect to the rates offered on deposits.
−Removed: Our global card network competes in the global payments industry with other card networks, including, among others, China UnionPay, Visa, Mastercard, JCB, Discover and Diners Club International (which is owned by Discover).
−Removed: We are the fourth largest general-purpose card network globally based on purchase volume, behind China UnionPay, Visa and Mastercard.
−Removed: In addition to such networks, a range of companies globally, including merchant acquirers, processors and web- and mobile-based payment platforms (e.g., Alipay, PayPal and Venmo), as well as regional payment networks (such as the National Payments Corporation of India), carry out some activities similar to those performed by our GMNS business.
−Removed: The principal competitive factors that affect the card-issuing, merchant and network businesses include:
−Removed: • The features, value and quality of the products and services, including customer care, rewards programs, partnerships, travel and lifestyle-related benefits, and digital and mobile services, as well as the costs associated with providing such features and services
+Added: Our global card network competes in the global payments industry with other card networks, including, among others, Visa, China UnionPay, Mastercard, JCB, Discover and Diners Club International (which is owned by Discover).
+Added: We are the fourth largest general-purpose card network globally based on purchase volume, behind Visa, China UnionPay and Mastercard.
+Added: In addition to such networks, we compete against a range of companies globally, including merchant acquirers, processors and web- and mobile-based payment platforms (e.g., Alipay, PayPal and Shop Pay), as well as regional payment networks (such as the National Payments Corporation of India).
+Added: The principal competitive factors that affect card-issuing, merchant and network businesses include:
+Added: • The features, value and quality of the products and services, including customer care, rewards programs and offers, partnerships, travel and lifestyle-related benefits (including lounges, dining and other entertainment), banking services and digital and mobile services, as well as the costs associated with providing such features and services
• Reputation and brand recognition
1 unchanged sentence
• The quantity, diversity and quality of the establishments where the cards can be used
−Removed: • The attractiveness of the value proposition to card issuers, merchant acquirers, cardholders, corporate clients and merchants (including the relative cost of using or accepting the products and services, and capabilities such as fraud prevention and data analytics)
−Removed: • The number and quality of other cards and other forms of payment and financing available to customers
+Added: • The attractiveness of the value proposition to card issuers, merchant acquirers, third-party processors, cardholders, corporate clients, merchants and other payment intermediaries (including the relative cost and ease of using or accepting the products and services, and capabilities such as fraud prevention and data analytics)
+Added: • The number, quality and cost of other cards and other forms of payment and financing available to customers, as well as the integration and connectivity of those products
+Added: • The security of cardholder, merchant and network partner information
• The success of marketing and promotional campaigns
1 unchanged sentence
• The nature and quality of expense management tools, electronic payment methods and data capture and reporting capabilities, particularly for business customers
−Removed: • The security of cardholder, merchant and network partner information
Another aspect of competition is the dynamic and rapid growth of alternative payment and financing mechanisms, systems and products, which include payment facilitators and aggregators, digital payment, open banking and electronic wallet platforms, point-of-sale lenders and buy now, pay later products, real-time settlement and processing systems, financial technology companies, digital currencies developed by both central banks and the private sector, blockchain and similar distributed ledger technologies, prepaid systems and gift cards, and systems linked to customer accounts or that provide payment solutions.
−Removed: Various competitors are integrating more financial services into their product offerings and competitors are seeking to attain the benefits of closed-loop, loyalty and rewards functionalities, such as ours.
+Added: The integration of new or evolving technologies, such as generative artificial intelligence, has the potential to create new or better competitor products, alter the competitive environment and disintermediate our relationship with customers.
+Added: Additionally, various competitors are integrating more financial services into their product offerings and competitors are seeking to attain the benefits of an integrated payments platform, such as ours.
In addition to the discussion in this section, see “ Our operating results may materially suffer because of substantial and increasingly intense competition worldwide in the payments industry ” under “Risk Factors” for further discussion of the potential impact of competition on our business, and “ Our business is subject to evolving and comprehensive government regulation and supervision, which could materially adversely affect our results of operations and financial condition ” and “ Legal proceedings regarding provisions in our merchant contracts, including non-discrimination and honor-all-cards provisions, could have a material adverse effect on our business and result in additional litigation and/or arbitrations, changes to our merchant agreements and/or business practices, substantial monetary damages and damage to our reputation and brand ” under “Risk Factors” for a discussion of the potential impact on our ability to compete effectively due to government regulations or if ongoing legal proceedings limit our ability to prevent merchants from engaging in various actions to discriminate against our card products.
5 unchanged sentences
We have also been subject to regulatory actions and may continue to be the subject of such actions, including governmental inquiries, investigations, enforcement proceedings and the imposition of fines or civil money penalties, in the event of noncompliance or alleged noncompliance with laws or regulations.
−Removed: For example, as previously disclosed, we are cooperating with governmental investigations related to certain of our historical sales practices, which are described in more detail in Note 12 to the “Consolidated Financial Statements.” External publicity concerning investigations can increase the scope and scale of those investigations and lead to further regulatory inquiries.
+Added: For example, as previously disclosed, we entered into agreements to resolve governmental investigations related to historical sales practices for certain U.S.
+Added: small business customers, which are described in more detail in Note 12 to the “Consolidated Financial Statements.” In addition, various regulatory agencies have announced they are reviewing credit card rewards programs for compliance with consumer protection laws and regulations.
+Added: We have identified certain issues related to the rewards and benefits we provide including, as previously disclosed, that certain U.S.
+Added: Card Members were not credited certain Membership Rewards points they had earned.
+Added: We have taken actions to remediate these issues and enhance our related procedures and controls.
+Added: We are cooperating with ongoing regulatory inquiries concerning our rewards and benefits programs.
Policymakers around the world continue to propose and adopt new and increasingly complex laws and regulations governing a wide variety of issues that may impact our business or change our operating environment in substantial and unpredictable ways.
10 unchanged sentences
The Company and its subsidiaries are also subject to the rulemaking, enforcement and examination authority of the Consumer Financial Protection Bureau (CFPB).
−Removed: Banking regulators have broad examination and enforcement power, including the power to impose substantial fines, limit dividends and other capital distributions, restrict operations and acquisitions and require divestitures, any of which could compromise our competitive position.
+Added: Banking regulators have broad examination and enforcement powers, including the power to impose substantial fines, limit dividends and other capital distributions, restrict operations and acquisitions and require divestitures, any of which could compromise our competitive position.
Many aspects of our business also are subject to rigorous regulation by other U.S.
6 unchanged sentences
As noted above, each of the Company and TRS is a bank holding company and each has elected to become a financial holding company, which is authorized to engage in a broader range of financial and related activities.
−Removed: In order to remain eligible for financial holding company status, we must meet certain eligibility requirements.
+Added: In order to remain eligible for financial holding company status, the Company and TRS must meet certain eligibility requirements.
Those requirements include that each of the Company and AENB must be “well capitalized” and “well managed,” and AENB must have received at least a “satisfactory” rating on its most recent assessment under the Community Reinvestment Act of 1977 (the CRA).
−Removed: The Company and TRS engage in various activities permissible only for financial holding companies, including, in particular, providing travel agency
−Removed: services, acting as a finder and engaging in certain insurance underwriting and agency services.
+Added: The Company, TRS and their subsidiaries engage in various activities permissible only for financial holding companies, including, in particular, providing travel agency services, acting as a finder and engaging in certain insurance underwriting and agency services.
If the Company fails to meet eligibility requirements for financial holding company status, it and its subsidiaries are likely to be barred from engaging in new types of financial activities or making certain types of acquisitions or investments in reliance on its status as a financial holding company, and ultimately could be required to either discontinue the broader range of activities permitted to financial holding companies or divest AENB.
7 unchanged sentences
federal bank regulatory agencies’ rules that tailor the application of enhanced prudential standards to bank holding companies and depository institutions with $100 billion or more in total consolidated assets.
−Removed: Under these rules, each such bank holding company, as well as its bank subsidiaries, is assigned to one of four categories based on its status as a U.S.
+Added: Under these rules, each such bank holding company is assigned to one of four categories based on its status as a U.S.
global systemically important banking organization and five other risk-based indicators:
(i) total assets, (ii) cross-jurisdictional activity, (iii) non-bank assets, (iv) off-balance sheet exposure, and (v) weighted short-term wholesale funding, with the most stringent requirements applying to Category I firms and the least stringent requirements applying to Category IV firms.
−Removed: Under these rules, the Company (and its depository institution subsidiary, AENB) is currently subject to Category IV standards.
−Removed: However, changes in the levels of these risk-based indicators at the Company could result in changes to our regulatory tailoring category.
−Removed: Category III firms include those firms with greater than $250 billion but less than $700 billion in total consolidated assets, calculated based on a four-quarter trailing average.
−Removed: Our total consolidated assets were $251 billion and $261 billion as of September 30 and December 31, 2023, respectively, and, accordingly, we anticipate becoming a Category III firm in 2024.
−Removed: Category III firms are subject to heightened capital, liquidity and prudential requirements, single-counterparty credit limits and additional stress tests, which in some cases are subject to a transition period following a financial institution becoming a Category III firm.
−Removed: Moreover, further changes in the risk-based indicators described above, such as if we have $75 billion or more in cross-jurisdictional activity (calculated based on a four-quarter trailing average), could result in us becoming a Category II firm and subject to more stringent capital, liquidity and prudential requirements.
+Added: Under these rules, the Company became a Category III firm in the third quarter of 2024 as a result of the Company’s total consolidated assets exceeding $250 billion, calculated based on a daily average of total consolidated assets for the four quarters ended June 30, 2024.
+Added: Category III firms are subject to heightened capital, liquidity and prudential requirements, single-counterparty credit limits and additional stress tests, which in some cases are subject to a transition period.
+Added: AENB, as a depository institution subsidiary of a Category III firm, is also subject to certain enhanced prudential standards under these tailoring rules as described below.
+Added: Further changes in the levels of risk-based indicators described above, such as if we have $75 billion or more in cross-jurisdictional activity (based on a four-quarter trailing average), could result in the Company becoming a Category II firm and subject to more stringent capital, liquidity and prudential requirements.
Our cross-jurisdictional activity was $66 billion as of December 31, 2024, and the four-quarter trailing average was $67 billion.
7 unchanged sentences
We report our capital adequacy ratios using risk-weighted assets calculated under the standardized approach.
−Removed: Category IV firms such as us and Category III firms are not subject to the advanced approaches capital requirements, whereas Category II firms are subject to the advanced approaches capital requirements under current capital rules, which introduce additional complexities in the methodologies used to calculate risk-weighted assets for purposes of determining capital adequacy ratios.
+Added: Category III firms such as the Company are not subject to the advanced approaches capital requirements, whereas Category II firms are subject to the advanced approaches capital requirements under current capital rules, which introduce additional complexities in the methodologies used to calculate risk-weighted assets for purposes of determining capital adequacy ratios.
On July 27, 2023, the U.S.
6 unchanged sentences
The proposed rules would also include additional credit risk capital requirements for certain “unconditionally cancellable commitments” such as unused portions of committed lines of credit (e.g., credit cards) and would create a proxy methodology to assign capital requirements to credit exposure on products that carry no pre-set spending limits such as charge cards.
−Removed: Under the proposal, the revisions would become effective on July 1, 2025, subject to a three-year transition period for certain provisions, including phasing in the use of risk-weighted assets under the expanded risk-based approach.
−Removed: While the U.S.
−Removed: federal bank regulatory agencies have solicited comments on the proposal and the rule may not be adopted as proposed, based on a preliminary analysis, we estimate that the increase in our risk-weighted assets under the expanded risk-based approach as currently proposed could consume the capital buffer between our minimum regulatory requirements and our current CET1 risk-based capital ratio.
−Removed: See below for additional information on our minimum CET1 regulatory requirement and “Consolidated Capital Resources and Liquidity — Capital Strategy” under “MD&A” for additional information on our current CET1 risk-based capital ratio.
−Removed: This estimated impact reflects our current understanding of the proposal, the application to our businesses as currently conducted and the current composition of our balance sheet, and therefore does not reflect the impact of any changes we may make in the future as a result of the expanded risk-based approach or otherwise.
−Removed: The ultimate impact will depend on the final rulemaking, future minimum regulatory requirements as well as management decisions regarding our product constructs, capital distributions and target capital levels, and the actual impact of any final rule could materially differ from our current estimate.
−Removed: In December 2018, federal banking regulators issued a final rule that provides an optional three-year phase-in period for the adverse regulatory capital effects of adopting the Current Expected Credit Loss (CECL) methodology pursuant to new accounting guidance for the recognition of credit losses on certain financial instruments, which became effective January 1, 2020.
−Removed: In August 2020, federal banking regulators issued a final rule that provides an option to delay the estimated impact of the adoption of the CECL methodology on regulatory capital for up to two years, followed by the three-year phase-in period at 25 percent once per year beginning in January 1, 2022.
−Removed: We elected to delay the recognition of $0.7 billion of reduction in regulatory capital from the adoption of the CECL methodology for two years, followed by the three-year phase-in period.
−Removed: As of January 1, 2024, the Company has phased in 75 percent of such amount.
−Removed: See “Critical Accounting Estimates” under “MD&A” for additional information on CECL.
+Added: The Federal Reserve has issued public statements indicating that it intends to work with other U.S.
+Added: federal bank regulatory agencies on a revised proposal;
+Added: however, any future rulemaking with respect to Basel III standards remains uncertain.
+Added: The ultimate impact of any such rulemaking will depend on a number of factors, including the content of the final rulemaking, future minimum regulatory requirements and management decisions regarding our product constructs, capital distributions and target capital levels, and such rulemaking could result in significantly higher regulatory capital requirements for the Company and AENB.
The Company and AENB must each maintain CET1 capital, Tier 1 capital and Total capital ratios of at least 4.5 percent, 6.0 percent and 8.0 percent, respectively.
1 unchanged sentence
The SCB equals (i) the difference between a bank holding company’s starting and minimum projected CET1 capital ratios under the supervisory severely adverse scenario under the Federal Reserve’s stress tests described below, plus (ii) one year of planned common stock dividends as a percentage of risk-weighted assets.
−Removed: On July 27, 2023, the Federal Reserve confirmed the SCB for the Company of 2.5 percent, which remained unchanged from the level announced in August 2022.
+Added: As a Category III firm, the required minimum capital ratios for the Company may be further increased by a countercyclical capital buffer of up to an additional 2.5 percent of risk-weighted assets, if enacted by the Federal Reserve, which must be held in the form of CET1 capital.
+Added: The countercyclical capital buffer is currently set at zero percent;
+Added: however it could change in the future.
+Added: If the Federal Reserve were to raise the countercyclical capital buffer, covered banking organizations such as the Company would generally have 12 months after the announcement of such increase to meet the increased buffer requirement, unless the Federal Reserve sets an earlier effective date.
+Added: On August 28, 2024, the Federal Reserve confirmed the SCB for the Company of 2.5 percent, which remained unchanged from the level announced in July 2023.
As a result, the effective minimum ratios for the Company (taking into account the SCB requirement) and AENB (taking into account the CCB requirement) are 7.0 percent, 8.5 percent and 10.5 percent for the CET1 capital, Tier 1 capital and Total capital ratios, respectively.
−Removed: Banking organizations whose ratios of CET1 capital, Tier 1 capital or Total capital to risk-weighted assets are below these effective minimum ratios face constraints on discretionary distributions such as dividends, repurchases and redemptions of capital securities, and executive compensation.
+Added: Banking organizations with ratios of CET1 capital, Tier 1 capital or Total capital to risk-weighted assets below these effective minimum ratios face constraints on discretionary distributions such as dividends, repurchases and redemptions of capital securities and executive compensation.
A bank holding company’s SCB requirement is effective on October 1 of each year and will remain in effect through September 30 of the following year unless it is reset in connection with resubmission of a capital plan, as discussed below.
−Removed: Category III firms are also subject to (i) if enacted by the Federal Reserve, a CET1 countercyclical capital buffer requirement of up to an additional 2.5 percent and (ii) a minimum supplementary leverage ratio of 3.0 percent that takes into account both on‐balance sheet and certain off‐balance sheet exposures.
−Removed: We are also required to comply with minimum leverage ratio requirements.
+Added: The Company is also required to comply with minimum leverage ratio requirements.
The leverage ratio is the ratio of a banking organization’s Tier 1 capital to its average total consolidated assets (as defined for regulatory purposes).
−Removed: All banking organizations are required to maintain a leverage ratio of at least 4.0 percent.
+Added: The Company is also subject to a minimum supplementary leverage ratio, which is the ratio of Tier 1 capital to an expanded concept of leverage exposure that takes into account both on‐balance sheet assets and certain off‐balance sheet exposures.
+Added: All banking organizations are required to maintain a leverage ratio of at least 4.0 percent, and Category III banking organizations such as the Company are required to maintain a minimum supplementary leverage ratio of 3.0 percent.
Liquidity Regulation
−Removed: The Federal Reserve’s enhanced prudential standards rule includes heightened liquidity and overall risk management requirements.
−Removed: The rule requires the maintenance of a liquidity buffer, consisting of highly liquid assets, that is sufficient to meet projected net outflows for 30 days over a range of liquidity stress scenarios, and a minimum liquidity coverage ratio (LCR) that measures a firm’s high-quality liquid assets to its projected net outflows.
−Removed: A second standard provided for in the Basel III liquidity framework, referred to as the net stable funding ratio (NSFR), requires a minimum amount of longer-term funding based on the assets and activities of banking entities.
−Removed: As a Category IV firm with less than $50 billion in weighted short-term wholesale funding, we are not currently subject to a specific LCR or NSFR requirement;
−Removed: however, as described above, we anticipate becoming a Category III firm in 2024.
−Removed: Category III firms and their depository institution subsidiaries are subject to LCR and NSFR requirements but at a reduced level (that is, at 85 percent of the full requirements), unless they have $75 billion or more in weighted short-term wholesale funding, in which case the full requirements would apply.
+Added: The Company and AENB are subject to two standards for liquidity risk supervision as implemented by the Federal Reserve and OCC:
+Added: the minimum liquidity coverage ratio (LCR) and the net stable funding ratio (NSFR).
+Added: The LCR is designed to ensure that a banking entity maintains an adequate level of unencumbered high-quality liquid assets to meet its liquidity needs for a 30-day time horizon under an acute liquidity stress scenario specified by supervisors.
+Added: The LCR measures the ratio of a firm’s high-quality liquid assets to its projected net outflows.
+Added: The NSFR requires a minimum amount of longer-term funding sources based on the assets, commitments and derivative exposures of banking entities.
+Added: As a Category III firm with less than $75 billion in weighted short-term wholesale funding, the Company, and its depository institution subsidiary, AENB, are subject to LCR and NSFR requirements at 85 percent of the full requirements.
+Added: The Company and AENB are required to calculate the LCR and NSFR on a daily basis and the Company is required to make public disclosures related to its LCR on a quarterly basis and NSFR on a semi-annual basis, in each case, subject to applicable transition periods following the Company becoming a Category III firm.
Category II firms and their depository institution subsidiaries are subject to the full requirements of the LCR and NSFR, as well as a requirement to submit a liquidity monitoring report on a daily (rather than monthly) basis.
+Added: In addition, the Federal Reserve’s enhanced prudential standards rule includes heightened liquidity and risk management requirements.
+Added: The rule requires the maintenance of a liquidity buffer, consisting of highly liquid assets, that is sufficient to meet projected net outflows for 30 days over a range of liquidity stress scenarios.
+Added: In contrast to the LCR, which is a standardized approach, the liquidity buffer requirement is calculated based on the Company’s own models.
Proposed Long-Term Debt Requirements
3 unchanged sentences
Stress Testing and Capital Planning
−Removed: Under the Federal Reserve’s regulations, the Company is subject to supervisory stress testing requirements that are designed to evaluate whether a bank holding company has sufficient capital on a total consolidated basis to absorb losses and support operations under adverse economic conditions.
+Added: Under the Federal Reserve’s regulations, the Company is subject to annual supervisory stress testing requirements and biennial company-run stress testing requirements (commonly referred to as Dodd-Frank Act Stress Tests or “DFASTs”) that are designed to evaluate whether a bank holding company has sufficient capital on a total consolidated basis to absorb losses and support operations under adverse economic conditions.
As part of the Comprehensive Capital Analysis and Review (CCAR), the Federal Reserve uses pro-forma capital positions and ratios under such stress scenarios to determine the size of the SCB for each CCAR participating firm.
−Removed: Because the Company is currently a Category IV firm, it is required to participate in the supervisory stress tests every other year and is subject to the Federal Reserve’s supervisory stress tests in 2024.
−Removed: The Company is required to develop and submit to the Federal Reserve an annual capital plan on or before April 5 of each year.
−Removed: For Category IV firms, the portion of the SCB based on the Federal Reserve’s supervisory stress tests is calculated every other year.
−Removed: During a year in which a Category IV firm does not undergo a supervisory stress test, the firm receives an updated SCB that reflects the firm’s updated planned common stock dividends.
−Removed: A Category IV firm can elect to participate in the supervisory stress test in an “off year” and consequently receive an updated SCB.
−Removed: We may be required to revise and resubmit our capital plan following certain events or developments, such as a significant acquisition or an event that could result in a material change in our risk profile or financial condition.
−Removed: If we are required to resubmit our capital plan, we must receive prior approval from the Federal Reserve for any capital distributions (including common stock dividend payments and share repurchases), other than a capital distribution on a newly issued capital instrument.
−Removed: Category III firms are subject to annual supervisory stress tests, with the SCB calculated each year, and must conduct company‐run stress tests every other year (commonly referred to as Dodd‐Frank Act Stress Tests or “DFASTs”).
−Removed: Category II firms must conduct company-run stress tests on an annual basis rather than every other year.
+Added: As a Category III firm, the Company is required to develop and submit to the Federal Reserve an annual capital plan and stress testing results on or before April 5 of each year.
+Added: The Company may be required to revise and resubmit its capital plan following certain events or developments, such as a significant acquisition or an event that could result in a material change in its risk profile or financial condition.
+Added: If the Company is required to resubmit its capital plan, it must receive prior approval from the Federal Reserve for any capital distributions (including common stock dividend payments and share repurchases), other than a capital distribution on a newly issued capital instrument.
Dividends and Other Capital Distributions
The Company and TRS, as well as AENB and the Company’s insurance and other regulated subsidiaries, are limited in their ability to pay dividends by statutes, regulations and supervisory policy.
−Removed: Common stock dividend payments and share repurchases by the Company are subject to the oversight of the Federal Reserve, as described above.
+Added: Common stock dividend payments and share repurchases by the Company are subject to the oversight of the Federal Reserve and the outcome of the annual CCAR stress testing exercise, as described above.
The Company will be subject to limitations and restrictions on capital distributions if, among other things, (i) the Company’s regulatory capital ratios do not satisfy applicable minimum requirements and buffers or (ii) the Company is required to resubmit its capital plan.
11 unchanged sentences
If a federal regulator determines that we are in an unsafe or unsound condition or that we are engaging in unsafe or unsound banking practices, the regulator may reclassify our capital category or otherwise place restrictions on our ability to accept or solicit brokered deposits.
−Removed: Resolution Planning
+Added: Resolution and Recovery Planning
Certain bank holding companies are required to submit resolution plans to the Federal Reserve and FDIC providing for the company’s strategy for rapid and orderly resolution in the event of its material financial distress or failure.
−Removed: However, Category IV firms are not required to submit a holding company resolution plan, while Category III firms are required to submit a holding company resolution plan every three years.
+Added: As a Category III firm, the Company is required to submit a holding company resolution plan every three years, with submissions alternating between a full plan and a plan targeted on certain areas or subjects identified by the Federal Reserve and the FDIC.
+Added: The Company’s next holding company resolution plan is required to be submitted by October 1, 2025.
+Added: If the Federal Reserve and the FDIC determine that the Company’s plan is not credible and we fail to cure the deficiencies, we may be subject to more stringent capital, leverage or liquidity requirements;
+Added: may be subject to more restrictions on our growth, activities or operations;
+Added: or may ultimately be required to divest certain assets or operations to facilitate an orderly resolution.
AENB continues to be required to prepare and provide a separate resolution plan to the FDIC that would enable the FDIC, as receiver, to effectively resolve AENB under the FDIA in the event of failure.
−Removed: Under the FDIC’s rule and its accompanying June 2021 statement on resolution plans for insured depository institutions, insured depository institutions with $100 billion or more in assets, such as AENB, are required to submit resolution plans on a three-year cycle.
−Removed: AENB submitted its most recent resolution plan in December 2022, as required.
−Removed: On August 29, 2023, the FDIC issued a notice of proposed rulemaking that would require insured depository institutions with $100 billion or more in assets, including AENB, to submit full resolution plans every two years with interim supplements in non-submission years.
−Removed: Under the proposal, resolution plans would be subject to more stringent standards with respect to their assumptions and content, as well as enhanced credibility standards for the FDIC’s evaluation of resolution plans and expanded expectations regarding engagement and capabilities testing.
+Added: In June 2024, the FDIC issued a final rule revising its resolution plan requirements for insured depository institutions, which requires certain insured depository institutions with $100 billion or more in assets, including AENB, to submit full resolution plans every three years with interim supplements in non-submission years.
+Added: Under the final rule, resolution plans are subject to more stringent standards with respect to their assumptions and content, as well as enhanced credibility standards for the FDIC’s evaluation of resolution plans and expanded expectations regarding engagement and capabilities testing.
+Added: AENB will be required to submit its initial resolution plan under the final rule on or before July 1, 2026, with its initial interim supplement due on or before July 1, 2025.
+Added: In October 2024, the OCC issued final revisions to its recovery planning guidelines, which expand the recovery planning guidelines to apply to insured national banks with $100 billion or more in total consolidated assets, including AENB.
+Added: The OCC’s recovery planning guidelines require a covered bank to develop, maintain and test a recovery plan that, among other things, identifies a range of options that could be undertaken by the covered bank to restore its financial strength and viability when it experiences considerable financial or operational stress, but has not deteriorated to the point that resolution is imminent.
+Added: AENB will be required to develop a recovery plan by December 31, 2025 and test it by December 31, 2026, with testing then required periodically (but not less than annually) and following any significant changes to the recovery plan made in response to a material event.
Orderly Liquidation Authority
36 unchanged sentences
The FDIC’s deposit insurance fund is funded by assessments on insured depository institutions, including AENB, which are subject to adjustment by the FDIC.
−Removed: On November 16, 2023, the FDIC adopted a final rule imposing a special assessment to recover the cost associated with protecting uninsured depositors in connection with the failures of two U.S.
−Removed: banks in March 2023.
−Removed: The special assessment will total approximately $53 million for us (which amount was recognized as an expense in the fourth quarter of 2023), and will be paid over eight quarterly assessment periods, with the first quarterly assessment period beginning on January 1, 2024.
Community Reinvestment Act
2 unchanged sentences
In October 2023 , the U.S.
−Removed: regulatory agencies adopted a final rule that makes extensive revisions to the CRA regulatory framework, including to the definition of “limited purpose bank,” which could impact AENB and alter its CRA compliance obligations.
−Removed: Certain provisions of the final rule become effective on April 1, 2024, but the majority of the final rule’s operative provisions (including the revisions to the definition of “limited purpose bank”) become effective on January 1, 2026, with additional data collection and reporting requirements becoming effective on January 1, 2027.
−Removed: We are currently evaluating the impact of the final rule but expect that it will increase AENB’s obligations and compliance costs.
+Added: federal bank regulatory agencies adopted a final rule that makes extensive revisions to the CRA regulatory framework, including to the definition of “limited purpose bank,” which could impact AENB and alter its CRA compliance obligations.
+Added: In March 2024, a preliminary injunction was granted postponing the effectiveness of the final rule and the implementation dates until the resolution of litigation challenging the final rule;
+Added: whether the final rule will ultimately be implemented and any related compliance deadlines remain uncertain.
Climate Risk Management
−Removed: federal bank regulatory agencies have recently increased their focus on climate risk-related supervision.
−Removed: For example, on October 24, 2023, the U.S.
−Removed: federal bank regulatory agencies issued “Principles for Climate-Related Financial Risk Management for Large Financial Institutions.” The principles would apply to financial institutions with more than $100 billion in total consolidated assets, like the Company and AENB, and are broadly designed to provide a high-level framework for the safe and sound management of exposures to climate-related financial risks consistent with existing U.S.
+Added: In October 2023, the U.S.
+Added: federal bank regulatory agencies issued “Principles for Climate-Related Financial Risk Management for Large Financial Institutions.” The principles apply to financial institutions with more than $100 billion in total consolidated assets, like the Company and AENB, and are broadly designed to provide a high-level framework for the safe and sound management of exposures to climate-related financial risks consistent with existing U.S.
federal bank regulatory agencies’ rules and guidance.
6 unchanged sentences
In addition, the principles offer risk assessment guidance for incorporating climate-related financial risks in various traditional risk categories.
−Removed: It is too early to determine what other regulations and policies may be adopted or apply to the Company and AENB and the effect of any such regulations or policies on the Company and AENB.
Consumer Financial Products Regulation
7 unchanged sentences
federal law also regulates abusive debt collection practices, which, along with bankruptcy and debtor relief laws, can affect our ability to collect amounts owed to us or subject us to regulatory scrutiny.
−Removed: On February 1, 2023, the CFPB issued a proposed rule to lower the safe harbor amount that would be considered, by regulation, to be “reasonable and proportional” to the costs incurred by credit card issuers for late payments.
−Removed: The proposed rule would also eliminate the annual inflation adjustment for such safe harbor amount and prohibit late fee amounts above 25 percent of the consumer’s required minimum payment.
−Removed: On March 30, 2023, the CFPB adopted a final rule requiring covered financial institutions, such as us, to collect and report data to the CFPB regarding certain small business credit applications.
−Removed: Based on our small business credit transaction volume, we will be required to comply with this rule by October 1, 2024, subject to the outcome of litigation over the final rule.
−Removed: On October 19, 2023, the CFPB issued a proposed rule on personal financial data rights that the CFPB stated would accelerate a shift toward open banking.
−Removed: The proposed rule would require data providers to provide consumers and consumer-authorized third parties with access to consumers’ financial data free of charge and would also impose requirements on authorized third parties, as well as data aggregators that facilitate access to consumers’ financial data.
−Removed: If the proposed rule is adopted as proposed, it (and other open banking initiatives) has the potential to change the competitive landscape, which would present new challenges and opportunities to our business model.
+Added: The CFPB and other regulators have recently had a heightened focus on fees, rewards and other practices related to credit cards.
+Added: For example, in March 2024, the CFPB issued a final rule lowering the safe harbor amount for credit card late fees that would be considered “reasonable and proportional” to the costs incurred by credit card issuers for late payments to eight dollars, eliminating a higher late fee safe harbor amount for subsequent late payments and eliminating the annual inflation adjustment for the safe harbor amount.
+Added: In May 2024, a preliminary injunction was granted staying the effectiveness of the final rule;
+Added: however, whether the final rule will ultimately be implemented remains uncertain.
+Added: In addition, the CFPB and the U.S.
+Added: Department of Transportation (DOT) have launched inquiries focused on credit card and airline rewards programs, with the CFPB issuing a circular to other agencies in December 2024 addressing the design, marketing and administration of credit card rewards programs.
+Added: In March 2023, the CFPB adopted a final rule requiring covered financial institutions, such as us, to collect and report data to the CFPB regarding certain small business credit applications.
+Added: Based on our small business credit transaction volume, we will be required to comply with this rule by July 18, 2025 and begin reporting data to the CFPB by July 1, 2026.
+Added: In October 2024, the CFPB issued a final rule on personal financial data rights that requires financial institutions, including us, and other financial service providers (collectively referred to as data providers) to provide consumers and consumer-authorized third parties with access to consumers’ financial data in electronic form free of charge.
+Added: At the earliest, for certain products, we will be required to comply with the rule beginning on April 1, 2026;
+Added: however, the compliance timeline is subject to change due to the outcome of pending litigation challenging the rule.
+Added: While the impact of the rule will depend upon a number of factors, including consumer behavior and the actions of data providers and recipients, open banking initiatives like this final rule have the potential to change the competitive landscape, presenting challenges to our business model, such as limiting advantages provided by our integrated payments platform, as well as opportunities since we may also act as an authorized third party and receive data from data providers.
We are also regulated in the United States under the “money transmitter” or “sale of check” laws in effect in most states.
1 unchanged sentence
Additionally, we are regulated under insurance laws in the United States and other countries where we offer insurance services.
+Added: Our merchant acquiring business, and the third-party merchant acquirers, aggregators and processors with whom we have relationships, are also subject to certain aspects of regulation under consumer protection laws, such as by the Federal Trade Commission.
In countries outside the United States, regulators continue to focus on a number of key areas impacting our card-issuing businesses, particularly consumer protection (such as in the European Union (EU), the United Kingdom and Canada) and responsible lending (such as in Australia, Mexico, New Zealand and Singapore), with increasing importance on and attention to customers and outcomes rather than just ensuring compliance with local rules and regulations.
+Added: For example, the Financial Conduct Authority’s Consumer Duty in the United Kingdom, among other things, requires firms to act to deliver “good outcomes” for retail customers with respect to products and services, price and value, consumer understanding and consumer support.
Regulators’ expectations of firms in relation to their compliance, risk and control frameworks continue to increase and regulators are placing significant emphasis on a firm’s systems and controls relating to the identification and resolution of issues.
1 unchanged sentence
Legislators and regulators in various countries in which we operate have focused on the operation of card networks, including through enforcement actions, legislation and regulations to change certain practices or pricing of card issuers, merchant acquirers and payment networks, and, in some cases, to establish broad regulatory regimes for payment systems.
−Removed: The EU, Australia, Canada and other jurisdictions have focused on interchange fees (that is, the fee paid by the bankcard merchant acquirer to the card issuer in payment networks like Visa and Mastercard), as well as the rules, contract terms and practices governing merchant card acceptance.
−Removed: Regulation and other governmental actions relating to pricing or practices could affect all networks directly or indirectly, as well as adversely impact consumers and merchants.
+Added: Pricing for card acceptance, including interchange fees (that is, the fee paid by the bankcard merchant acquirer to the card issuer in payment networks like Visa and Mastercard), has been a focus of legislators and regulators in Australia, Canada, the EU, the United States and other jurisdictions.
+Added: Recently, certain states in the United States have passed or are considering laws prohibiting interchange from being charged on all or certain components of transactions, such as sales tax and gratuities.
+Added: Jurisdictions have also sought to regulate various other aspects of network operations and contract terms and practices governing merchant card acceptance, including information associated with electronic transactions, such as state legislation regarding the use of specific merchant categories codes or limiting the use of transaction data.
+Added: Regulation and other governmental actions relating to operations, pricing or practices could affect all networks and/or acquirers directly or indirectly, as well as adversely impact consumers and merchants.
Among other things, regulation of bankcard fees has negatively impacted, and may continue to negatively impact, the discount revenue we earn, including as a result of downward pressure on our merchant discount rates from decreases in competitor pricing in connection with caps on interchange fees.
−Removed: In some cases, regulations also extend to certain aspects of our business, such as network and cobrand arrangements or the terms of card acceptance for merchants, and we have exited our network businesses in the EU and Australia as a result of regulation in those jurisdictions, for example.
−Removed: There is uncertainty as to when or how interchange fee caps and other provisions of the EU payments legislation might apply when we work with cobrand partners and agents in the EU.
−Removed: In a ruling issued on February 7, 2018, the EU Court of Justice confirmed the validity of fee capping and other provisions in circumstances where three-party networks issue cards with a cobrand partner or through an agent, although the ruling provided only limited guidance as to when or how the provisions might apply in such circumstances and remains subject to differing interpretations by regulators and participants in cobrand arrangements.
−Removed: On August 29, 2023, the Dutch Trade and Industry Appeals Tribunal referred questions to the EU Court of Justice on the interpretation of the application of the interchange fee caps in connection with an administrative proceeding by the Netherlands Authority for Consumers and Markets regarding our cobrand relationship with KLM Royal Dutch Airlines.
+Added: In some cases, regulations also extend to certain aspects of our business, such as network and cobrand arrangements or the terms of card acceptance for merchants.
+Added: For example, we exited our network business in the EU and Australia as a result of regulation in those jurisdictions.
+Added: In addition, there is uncertainty as to when or how interchange fee caps and other provisions of the EU payments legislation might apply when we work with cobrand partners and agents in the EU.
+Added: In 2018, the EU Court of Justice (CJEU) confirmed the validity of fee capping and other provisions in circumstances where three-party networks issue cards with a cobrand partner or through an agent, although its ruling provided only limited guidance as to when or how the provisions might apply in such circumstances and remains subject to differing interpretations by regulators and participants in cobrand arrangements.
+Added: In December 2024, the CJEU held a hearing on questions referred by the Dutch Trade and Industry Appeals Tribunal regarding the interpretation of the application of the interchange fee caps in connection with an administrative proceeding by the Netherlands Authority for Consumers and Markets regarding our cobrand relationship with KLM Royal Dutch Airlines;
+Added: the CJEU has not yet issued a decision.
Given differing interpretations by regulators and participants in cobrand arrangements, we are subject to regulatory action, penalties and the possibility we will not be able to maintain our existing cobrand and agent relationships in the EU.
See “ Our business is subject to evolving and comprehensive government regulation and supervision, which could materially adversely affect our results of operations and financial condition ” under “Risk Factors.”
−Removed: In various countries, such as certain Member States in the EU, Australia and Canada (other than in Quebec), merchants are permitted by law to surcharge card purchases.
+Added: In various countries, such as certain Member States in the EU, Australia and Canada (other than in the Province of Quebec), merchants are permitted by law to surcharge card purchases.
In addition, the laws of a number of states in the United States that prohibit surcharging have been overturned and certain states have passed or are considering laws to permit surcharging by merchants.
+Added: In jurisdictions allowing surcharging, we have seen an increase in merchant surcharging on American Express cards, particularly in certain merchant categories.
Surcharging is an adverse customer experience and could have a material adverse effect on us, particularly where it only or disproportionately impacts credit card usage or card usage generally, our Card Members or our business.
−Removed: In addition, other steering or differential acceptance practices that are permitted by regulation in some jurisdictions could also have a material adverse effect on us.
−Removed: See “ Surcharging or steering by merchants could materially adversely affect our business and results of operations ” under “Risk Factors.”
+Added: In addition, we also encounter steering or differential acceptance practices by merchants, which could also have a material adverse effect on us.
+Added: See “ Surcharging, steering or other differential acceptance practices by merchants could materially adversely affect our business and results of operations ” under “Risk Factors.”
In some countries, governments have established regulatory regimes that require international card networks to be locally licensed and/or to localize aspects of their operations.
3 unchanged sentences
The development and enforcement of these and other similar laws, regulations and policies may adversely affect our ability to compete effectively and maintain and extend our global network.
−Removed: Privacy, Data Protection, Data Governance, Information Security and Cybersecurity
−Removed: Regulatory and legislative activity in the areas of privacy, data protection, data governance and information security and cybersecurity continues to increase worldwide.
−Removed: We have established, and continue to maintain, policies and a governance framework to comply with applicable privacy, data protection, data governance and information security and cybersecurity laws and requirements, meet evolving customer and industry expectations and support and enable business innovation and growth;
+Added: Privacy, Data Protection, Data Management, Artificial Intelligence, Resiliency, Information Security and Cybersecurity
+Added: Regulatory and legislative activity in the areas of privacy, data protection, data management, artificial intelligence, resiliency, information security and cybersecurity continues to increase worldwide.
+Added: We have established, and continue to maintain, policies and a governance framework to comply with applicable privacy, data protection, data management, artificial intelligence, resiliency, information security and cybersecurity laws and requirements, meet evolving customer and industry expectations and support and enable business innovation and growth;
however, our policies and governance framework may be insufficient given the size and complexity of our business and heightened regulatory scrutiny.
−Removed: Our regulators are increasingly focused on ensuring that our privacy, data protection, data governance and cybersecurity-related policies and practices are adequate to inform customers of our data collection, use, sharing and/or security practices, to provide them with choices, if required, about how we use and share their information, and to appropriately safeguard their personal information and account access.
−Removed: Regulators are also focused on data management, technology infrastructure and architecture, technology operations, resiliency and business continuity, and third-party risk management policies and practices.
+Added: Our regulators are increasingly focused on ensuring that our privacy, data protection, data management, artificial intelligence, resiliency and cybersecurity-related policies and practices are adequate to inform customers of our data collection, use, sharing and/or security practices, to provide them with choices, if required, about how we use and share their information, and to appropriately safeguard their personal information and account access.
+Added: Regulators are also focused on end-to-end management of data, technology infrastructure and architecture, technology operations, resiliency and business continuity, and third-party risk management policies and practices, with regulatory expectations continuing to increase as we grow in size.
+Added: For example, the EU Digital Operational Resilience Act, which applies as of January 2025, requires EU financial entities to have a comprehensive governance and risk management framework for information and communications technology risk.
+Added: In addition, regulators and legislators have heightened their focus on the use of artificial intelligence and machine learning through the application of existing laws and regulations as well as by adopting new laws and regulations, such as the EU’s AI Act and state artificial intelligence legislation (e.g., Colorado AI Act).
+Added: These new and emerging laws and regulations are reshaping how we develop, deploy and manage artificial intelligence systems, including by imposing new obligations related to data use, recordkeeping, transparency and human oversight.
In the United States, certain of our businesses are subject to the privacy, disclosure and safeguarding provisions of the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations and guidance.
3 unchanged sentences
states and territories are considering similar requirements or have adopted laws, rules and regulations pertaining to privacy and/or information security and cybersecurity that may be more stringent and/or expansive than federal requirements.
−Removed: We are also subject to certain privacy, data protection, data governance and information security and cybersecurity laws in other countries in which we operate (including Member States in the EU, Australia, Canada, China, Japan, Hong Kong, India, Indonesia, Mexico, Singapore, Thailand and the United Kingdom), some of which are more stringent and/or expansive than those in the United States and some of which may conflict with each other.
+Added: We are also subject to certain privacy, data protection, data management, artificial intelligence, resiliency, information security and cybersecurity laws in other countries in which we operate (including Member States in the EU, Australia, Canada, China, Japan, Hong Kong, India, Indonesia, Mexico, Singapore, Thailand and the United Kingdom), some of which are more stringent and/or expansive than those in the United States and may conflict with each other.
Some jurisdictions have instituted or are considering instituting requirements that make it onerous to transfer personal data to other jurisdictions, and certain countries require in-country data processing and/or in-country storage of data.
−Removed: Compliance with such laws results in higher technology, administrative and other costs for us, could limit our ability to optimize the use of our closed-loop data, and could require use of local technology services.
+Added: Compliance with such laws results in higher technology, administrative and other costs for us, could limit our ability to optimize the use of our data, and could require use of local technology services.
Some of these laws also require us to provide foreign governments and other third parties broader access to our data and intellectual property.
Data breach and operational outage notification laws or regulatory activities to encourage such notifications and regulatory activity and laws around resiliency, business continuity and third-party risk management are also becoming more prevalent in jurisdictions outside the United States in which we operate.
−Removed: The EU General Data Protection Regulation (GDPR) and the equivalent UK GDPR impose legal and compliance obligations on companies that process personal data of individuals in the EU and UK, irrespective of the geographical location of the company, with the potential for significant fines for non-compliance (up to 4 percent of total annual worldwide revenue).
+Added: The EU and UK General Data Protection Regulations (GDPR) impose legal and compliance obligations on companies that process personal data of individuals in the EU and UK, irrespective of the geographical location of the company, with the potential for significant fines for non-compliance (up to 4 percent of total annual worldwide revenue).
These laws include, among other things, a requirement for prompt notice of data breaches, in certain circumstances, to affected individuals and supervisory authorities and restrictions on the cross-border transfers of EU or UK personal data.
3 unchanged sentences
We are also subject to certain data protection laws in Member States in the EU, which may be more stringent than the EU GDPR.
−Removed: Our data protection programs have become the subject of heightened scrutiny in certain Member States in the EU and we continue to make changes to our privacy practices and data governance to comply with these requirements.
+Added: Our data protection programs have become the subject of heightened scrutiny in certain Member States in the EU and we continue to make changes to our privacy practices and data management to comply with these requirements.
Anti-Money Laundering, Countering the Financing of Terrorism, Economic Sanctions and Anti-Corruption Compliance
1 unchanged sentence
Failure to maintain and implement adequate programs and policies and procedures for AML/CFT, sanctions and anti-corruption compliance could have material financial, legal and reputational consequences.
+Added: Additionally, our AML/CFT, sanctions and anti-corruption compliance programs may limit our ability to pursue certain business opportunities or affect our relationships with certain partners, service providers and other third parties.
Anti-Money Laundering and Countering the Financing of Terrorism
1 unchanged sentence
In the United States, the majority of AML/CFT requirements are derived from the Currency and Foreign Transactions Reporting Act and the accompanying regulations issued by the U.S.
−Removed: Department of the Treasury (collectively referred to as the Bank Secrecy Act), as amended by the USA PATRIOT Act of 2001 (the Patriot Act).
+Added: Department of the Treasury (collectively referred to as the Bank Secrecy Act), as amended by the USA PATRIOT Act of 2001.
The Anti-Money Laundering Act of 2020 (the AMLA), enacted in January 2021, amended the Bank Secrecy Act and is intended to comprehensively reform and modernize U.S.
4 unchanged sentences
Among other things, these laws and regulations generally require us to establish AML/CFT programs that meet certain standards, including policies and procedures to collect information from and verify the identities of our customers, and to monitor for and report suspicious transactions, in addition to other information gathering and recordkeeping requirements.
−Removed: programs have become the subject of heightened scrutiny in some countries, including certain Member States in the EU.
−Removed: Any errors, failures or delays in complying with AML/CFT laws, perceived deficiencies in our AML/CFT programs or association of our business with money laundering, terrorist financing, tax fraud or other illicit activity can give rise to significant supervisory, criminal and civil proceedings and lawsuits, which could result in significant penalties and forfeiture of assets, loss of licenses or restrictions on business activities, or other enforcement actions.
+Added: Our AML/CFT programs have become the subject of heightened scrutiny and any errors, failures or delays in complying with AML/CFT laws, deficiencies in our AML/CFT programs or association of our business with money laundering, terrorist financing, tax fraud or other illicit activity can give rise to significant supervisory, criminal and civil proceedings and lawsuits, which could result in significant penalties and forfeiture of assets, loss of licenses or restrictions on business activities, or other enforcement actions.
Economic Sanctions
−Removed: National governments and international bodies, such as the United Nations and the EU, have imposed economic sanctions against individuals, entities, vessels, governments and countries that endanger their interests or violate international norms of behavior.
+Added: National governments and international bodies, such as the United Nations and the EU, have imposed economic sanctions against individuals, entities, vessels, governments, regions and countries that endanger their interests or violate international norms of behavior.
Sanctions have been used to advance a range of foreign policy goals, including conflict resolution, counterterrorism, counternarcotics and promotion of democracy and human rights, among other national and international interests.
+Added: We maintain a global sanctions compliance program designed to meet the requirements of applicable sanctions regimes.
Failure to comply with such requirements could subject us to serious legal and reputational consequences, including criminal penalties.
2 unchanged sentences
OFAC regulations prohibit U.S.
−Removed: persons from engaging in financial transactions with or relating to, or other dealings involving, a targeted individual, entity, vessel, government or country without a license or other authorization and require U.S.
+Added: persons from engaging in financial transactions with or relating to, or other dealings involving, a targeted individual, entity, vessel, government or country without a license or other authorization.
+Added: OFAC regulations require U.S.
persons to block property and property interests of parties on OFAC’s Specially Designated Nationals and Blocked Persons List and entities owned 50 percent or more by one or more Specially Designated Nationals.
2 unchanged sentences
sanction programs.
−Removed: We maintain a global sanctions compliance program designed to meet the requirements of applicable sanctions regimes.
+Added: Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012, which added Section 13(r) to the Securities Exchange Act of 1934, as amended (the Exchange Act), an issuer is required to disclose in its annual or quarterly reports, as applicable, whether it or any of its affiliates knowingly engaged in certain activities, transactions or dealings relating to Iran or with individuals or entities designated pursuant to certain Executive Orders.
+Added: Disclosure is generally required even where the activities, transactions or dealings were conducted outside the United States by non-U.S.
+Added: affiliates in compliance with applicable law and whether or not the activities are sanctionable under U.S.
+Added: In 2024, we became aware that a third-party automated teller machine (ATM) network provider maintained a relationship with an Iranian bank identified on the Specially Designated Nationals and Blocked Persons list.
+Added: As a result, American Express Card Members had the ability to access ATMs located outside of Iran that were operated by the Iranian bank through our ATM authorization program.
+Added: We have identified approximately 37 such ATM transactions by Card Members.
+Added: We had negligible gross revenues and net profits attributable to these transactions.
+Added: We immediately suspended our relationship with the ATM network provider and do not intend to continue to engage in this activity.
+Added: In 2024, we also identified approximately 30 consumer accounts of individuals that may be, or may have been, employed by the Government of Iran.
+Added: We believe the accounts were used only for personal expenses.
+Added: We had negligible gross revenues and net profits attributable to these accounts.
+Added: All of the accounts are closed and we do not intend to continue to engage in this activity.
+Added: We voluntarily reported the above transactions and accounts to OFAC.
Anti-Corruption
13 unchanged sentences
financial regulators, including the Federal Reserve and the Securities and Exchange Commission (SEC), to adopt rules on incentive-based payment arrangements at specified regulated entities having at least $1 billion in total assets.
−Removed: In 2016, the federal banking regulators, the SEC, the Federal Housing Finance Agency and the National Credit Union Administration proposed revised rules on incentive-based compensation practices, which have not yet been finalized.
+Added: In 2016, the federal banking regulators, the SEC, the Federal Housing Finance Agency and the National Credit Union Administration proposed revised rules on incentive-based compensation practices, which were reproposed by certain of those agencies in 2024, but have not yet been finalized.
If these or other regulations are adopted in a form similar to what has been proposed, they will impose limitations on the manner in which we may structure compensation for our colleagues, which could adversely affect our ability to hire, retain and motivate key colleagues.
ADDITIONAL INFORMATION
−Removed: We maintain an Investor Relations website at http://ir.americanexpress.com.
+Added: We maintain an Investor Relations website at https://ir.americanexpress.com.
We make available free of charge, on or through this website, our annual, quarterly and current reports and any amendments to those reports as soon as reasonably practicable following the time they are electronically filed with or furnished to the SEC.
In addition, we routinely post financial and other information, some of which could be material to investors, on our Investor Relations website.
−Removed: Information regarding our corporate sustainability initiatives, including our Environmental, Social and Governance reports, are available on the Corporate Sustainability section of our website at http://about.americanexpress.com/corporate-sustainability.
+Added: Information regarding our corporate sustainability initiatives and related disclosures are available on the Corporate Sustainability section of our website at https://go.amex/esg.
The content of any of our websites referred to in this report is not incorporated by reference into this report or any other report filed with or furnished to the SEC.
We have included such website addresses only as inactive textual references and do not intend them to be active links.
−Removed: You can find certain statistical disclosures required of bank holding companies starting on page A-1, which are incorporated herein by reference.
−Removed: Our business as a whole has not experienced significant seasonal fluctuations, although network volumes tend to be moderately higher in the fourth quarter than in other quarters.
+Added: Our business as a whole has not experienced significant seasonal fluctuations, although billed business tends to be moderately higher in the fourth quarter than in other quarters.
As a result, the amount of Card Member loans and receivables outstanding tend to be moderately higher during that quarter.
1 unchanged sentence
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.